Net rental income which a company derived from an apartment building in its 1978 and 1979 taxation years (managed by an affiliated property management company) was income from property rather than income from an active business. Strayer J stated (at p. 5289):
The services which they [the taxpayer companies] provided to occupants were of a very limited nature and typical of what any owner of a modern apartment building would expect to have to provide. As such they must be seen as incidental to the making of revenue from property through the earning of rent.